GIR 100 2020

Maeda Ayres & Sarubbi

Professional notice

Only four years old and already among Brazil’s top firms for internal investigations, Maeda Ayres & Sarubbi is regularly called upon by high-profile clients, such as the independent investigation committee established by Vale’s board of directors to look into a major dam disaster.

The firm

The leaders of Maeda Ayres & Sarubbi were at the forefront of creating Brazil’s anti-corruption law, giving the firm a unique inside perspective into Brazil’s evolving white-collar space.

The boutique was created in 2016 by three former leading partners from Trench Rossi & Watanabe: Bruno Maeda, Erica Sarubbi and Carlos Ayres. Since then, the firm has continued to grow with a strict focus on helping clients build compliance programmes, investigate misconduct and respond to government enforcement actions. Now, the firm has four partners – two male and two female – and 25 associates.

Name partner Maeda’s anti-corruption and investigations expertise includes having worked on some of the country’s first FCPA investigations in the early 2000s and participating in the development of Brazil’s anti-corruption laws. At his former firm, Maeda led a sprawling bribery investigation into Brazilian state-controlled oil company Petrobras, working alongside Gibson Dunn & Crutcher in Brazil, together with fellow name partner Ayres.

Ayres, a GIR 40 under 40 nominee in 2020, has previous experience working for the US Securities and Exchange Commission in Washington, DC. He now regularly represents large Brazilian companies before authorities such as Brazil’s Federal Prosecution Service, and the Department of Justice and SEC in the US.

Similar to the other name partners, Erica Sarubbi has also built up an impressive resume. She has advised numerous Brazilian and international multinational corporations in anti-corruption cases, including Brazilian aircraft maker Embraer. She represented the company as it sought to resolve bribery allegations with authorities in the US and Brazil. She was recognised in GIR’s 40 under 40 in 2017 and Women in Investigations in 2015.

The Maeda Ayres founders worked on negotiations for Brazil’s Clean Companies Act, which passed in 2014, advocating for the introduction of leniency agreements. Maeda testified in public hearings before Brazilian authorities about proposals for the law.

Another partner is Fernanda Bidlovsky, who was named in GIR’s Women in Investigations in 2018. Bidlovsky was previously a senior lawyer at Trench Rossi Watanabe. She also worked as an in-house lawyer for US medical device producer Carestream where she handled compliance matters.

All four partners are bilingual in Portuguese and English, and Ayres speaks Spanish too.

Ayres, Maeda and Sarubbi are nominees in Who’s Who Legal: Business Crime Defence. Ayres and Maeda are also listed in Who’s Who Legal: Investigations.

Recent events

One of Maeda Ayres & Sarubbi’s most high-profile public engagements is an investigation into the collapse of mining company Vale’s dam in the municipality of Brumandinho. The dam failed in January, killing 228 people.  Maeda Ayres & Sarubbi worked alongside US law firm Smith Pachter McWhorter to conduct an independent investigation into the causes of the collapse on behalf of an independent committee put together by Vale’s board of directors. The firm submitted the results of the investigation in February 2020.

The firm has also assisted an internal investigation into Brazilian state utility Eletrobras in connection with Brazil’s Operation Car Wash, as well as interactions with authorities in the same matter.

Firm lawyers are also part of the first Brazilian monitorship team appointed by local federal prosecutors to assess the improvements in Brazilian construction company Odebrecht’s compliance programme. Odebrecht agreed to pay US$2.6 billion to US, Swiss and Brazilian authorities in 2016 in what was then the biggest-ever foreign bribery resolution.

Maeda Ayres & Sarubbi was retained by a special committee of independent board members to carry out an independent investigation into alleged bribery by investment company TPI Triunfo Participações in exchange for contracts after federal police launched their own probe.


As well as Vale, Eletrobras and Triunfo Participações, the boutique has worked with various other confidential multinationals in Brazil, the US, Germany and Switzerland.


The boutique is based in Brazil’s business hub, São Paulo.

Track record

At Trench Rossi, Sarubbi was the lead attorney on the Embraer case while still at Trench Rossi. The company in October 2016 agreed to pay a US$107 million penalty and US$98 million in disgorgement to resolve Foreign Corrupt Practices Act charges. In Brazil, the company agreed to pay around $20.5 million of the US fines to local authorities, including disgorgement of illegal profits into a federal fund and a penalty to Brazil’s securities and exchange commission.

Embraer was accused of bribing officials in the Dominican Republic, Saudi Arabia and Mozambique. The company signed a three-year deferred prosecution agreement with the DOJ and retained an independent corporate monitor, Ropes & Gray partner Alexandre Rene. The monitorship was concluded in June.

The Firm

Maeda, Ayres & Sarubbi is a unique Brazilian boutique law firm specialized in compliance, investigations and government enforcement, with extensive experience in various sectors of the economy.

Our firm was created in 2016 by the three visionary name partners: Bruno Maeda, Carlos Ayres and Erica Sarubbi. They were supported by a team of courageous lawyers, including their partner, Fernanda Bidlovsky.

Our ambition was to be different, by providing superb quality, by continuously enriching our knowledge in compliance, and by working openly and side by side with clients and partners on the most complex cases in the country. We also strive to make a positive impact on Brazilian society. 

The Team 

Our team, with its multidisciplinary profile and demand for excellence in every single delivery, is always expanding its vast experience in compliance. Our firm is led by four partners with broad recognition and credibility, which have been achieved through their deep understanding and influence of all compliance matters since its initial development in Brazil. 

Our lawyers are frequently consulted and interviewed about anti-corruption and compliance. Our firm and team are recognized by worldwide publications as leaders in internal investigations and compliance. Our partners, Erica Sarubbi and Fernanda Bidlovsky were ranked in the GIR "100 Woman in Investigations" and our partners Carlos Ayres and Erica Sarubbi were listed in the GIR "40 under 40" ranking, that elects the best lawyers under 40 years old worldwide.

The Cases 

We advise clients in a wide range of complex internal investigations. Our team has led some of the most high-profile investigations in Brazil. Moreover, our lawyers are part of the first Brazilian independent monitorship team, which was appointed by the Federal Prosecution Office (MPF) to follow the improvements of both the compliance program and internal controls of a Brazilian company involved in the Car Wash Operation. We also support the independent monitor that was appointed by the US authorities in one of the largest international fraud cases.

We are pioneers in agreements with Brazilian authorities under the  anti-corruption laws and experts at handling complex cooperation cases, including cases involving authorities of other jurisdictions. Additionally, we provide specialized legal defense for our clients before the Office of the Comptroller General (CGU) and other administrative authorities on Administrative Proceedings against Legal Entities ("PAR"), set forth in the Brazilian anti-corruption law (Law No. 12.846/2013). We represent clients in some of the most significant PAR proceedings in Brazil.

Additionally, as the pioneers in Compliance in Brazil, we have worked with dozens of companies in various sectors in the assessment and development of compliance programs in accordance with national and international legal requirements.

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